Privacy policy

 

This Privacy Policy (the “PRIVACY POLICY”) governs the processing of personal data that you (the “USER”) share with SOUZA CRUZ LTDA. (hereinafter referred to as “BAT BRASIL”) when using digital products, services, features and/or tools (collectively the “SERVICES”) made available to USERS by BAT BRASIL through its institutional Website or any other Website, application and/or digital platform owned by BAT Brazil or BAT Group  (collectively the “APPLICATIONS”).

In the course of its activities, BAT BRASIL collects a range of information regarding people with whom it interacts as part of conducting its business, and may use it as described in this PRIVACY POLICY. We, at  BAT BRASIL, reinforce our commitment to our USERS and our concern when it comes to the privacy and protection of their personal data. In case of any questions about this PRIVACY POLICY, please contact us through the channels indicated at the end of this document.

In case of disagreement with any clause or condition of the PRIVACY POLICY, we request that you do not use the SERVICES AND APPLICATIONS offered by BAT BRASIL. Any use of the SERVICES AND/OR APPLICATIONS, in whole or in part, shall imply immediate acceptance of the PRIVACY POLICY. By accessing the  APPLICATIONS and using the SERVICES, you express that you are aware of this PRIVACY POLICY governing your relationship with BAT BRASIL.

For the purposes of reading of this document we clarify that the terms “British American Tobacco,” “the Group” and the “British American Tobacco Group” are used to refer to British American Tobacco p.l.c. and the group of companies constituting its direct and indirect subsidiaries worldwide, including BAT BRASIL.

I. PERSONAL DATA COLLECTION

1.1. Through its Applications and the performance of its SERVICES, BAT BRASIL requests and obtains personal data from its USERS. Essentially, the personal data are sent by the USERS when signing up the APPLICATIONS and/or using the SERVICES offered by BAT BRASIL.

1.2. In view of the purpose of the Applications and of the SERVICES offered, personal data such as name, address, Individual Taxpayers’ Registry (CPF), telephone number, ID number and email contact address, among others, may be required for the full operation of the SERVICES AND APPLICATIONS. The USER hereby consents to the collection and processing of this data for the purposes informed in this PRIVACY POLICY.

1.3. If the USER wishes to purchase additional products or services offered in the APPLICATIONS, BAT BRASIL will collect additional data, which will be used solely for the purpose of making payment for the contracted SERVICES.

1.4. The personal data provided may be stored on servers located abroad – preferably in the United States, in view of the cloud services we use – and shall only be provided to third parties as provided for under the Law and/or by court order. By using the SERVICES AND APPLICATIONS, the USER expressly agrees to such international data transfer.

1.5. The data collected by BAT BRASIL are stored under the strictest information security practices in BAT BRASIL’S database (the “DATABASE”). The DATABASE is strictly supervised and protected, so that only qualified employees, who are contractually bound to the duties of secrecy and confidentiality, have access thereto. BAT BRASIL shall use its best efforts to ensure that the information is always processed in accordance with the provisions of this Privacy POLICY. However, BAT BRASIL cannot guarantee that data protection and security will never be violated. IN THESE CIRCUMSTANCES, THE USER AGREES THAT BAT BRASIL SHALL NOT BE HELD RESPONSIBLE FOR THE UNAUTHORIZED PRACTICE OF ANY ACTS BY THIRD PARTIES THAT PROMOTE THE INTERCEPTION, DELETION, ALTERATION, MODIFICATION OR MANIPULATION OF THE CONTENTS OF THE APPLICATIONS, PERSONAL DATA AND ANY OTHER INFORMATION AND MATERIALS MADE AVAILABLE BY THE USERS.

1.6. By using the APPLICATIONS and accessing BAT BRASIL’S website, certain  information regarding the USER, such as the Internet protocol (the “IP address”), operating system, time spent on the APPLICATIONS, among other information, will be stored by BAT BRASIL or by a company contracted for this purpose, which shall be contractually obliged to comply with the confidentiality and secrecy duties. These logs may be used, for example, for traffic analysis and use of the  APPLICATIONS. If they do not wish to provide this data, the USER may set their Internet browser to disable cookies, being aware that, in this case, the disabling of cookies may cause the features of the APPLICATIONS and of BAT BRASIL’s Website to work improperly.

1.7. In the performance of its activities, BAT BRASIL does not process any personal data of people under age. Should BAT BRASIL identify any data regarding people under age, they will be immediately excluded.

II. PERSONAL DATA PROCESSING

2.1. For the performance of the SERVICES, BAT BRASIL shall not share, lend or exchange the USER’ personal data with third parties for marketing or commercial purposes.

2.2. In the course of its activities, BAT BRASIL shares information with third parties, always with a view to improving the offer of its services, applications  and products, in the following cases: (i) any of the companies in the BAT group; (ii) Tax, audit or any other authorities, when we believe that we are legally obliged to do so and/or to help prevent fraud or protect BAT’s rights, protect the personal safety of BAT employees or third parties; (iii) service providers, such as off-counsels and professional consultants (including law firms, auditors and accountants), technical support roles, and IT consultants who perform testing and development work on our commercial technology systems; (iv) third parties for background check purposes, credit record checks, meeting of orders, delivery, customer support services and storage services; (v) third-party IT providers, including, but not limited to, email/text messaging providers, cloud IT service providers, business suite solution providers, data analytics agencies, strategic IT implementation partners, and hosting service providers; (vi) New business: In case of acquisition or merger of companies, establishment of business partnerships, joint ventures and any other businesses, in which case this PRIVACY POLICY shall remain in force; and (vii) compliance with legal obligations: BAT BRASIL may share information as necessary to comply with any and all legal determinations, whether judicial or administrative, in which case BAT BRASIL will notify the USER of what information will be shared. By accepting this  PRIVACY POLICY, the USER expressly agrees to these transactions, which may, in some cases, consist of international data transfers. In these cases,  BAT BRASIL adopts all technical measures necessary to ensure the personal data security.

2.4. BAT BRASIL values the privacy of its USERS and uses the personal data provided by them for the following purposes:

  • Performance of various digital products, services and/or tools contracted and made available to the USERS by BAT BRASIL through the APPLICATIONS. In order to meet this purpose, the personal data made available by the USERS may be shared with partners as described in this PRIVACY POLICY.
  • Contact the USER to confirm the information that has been provided and request the sending of information that is still pending so that BAT BRASIL can properly provide its SERVICES.
  • Prepare profiles and demographic trends of use of the website and/or of the APPLICATIONS.
  • The data may also be used in the management and improvement of the APPLICATIONS’ features, as well as for the customization of the services offered and the performance of statistics and studies. 
  • Meet the legitimate interests of BAT BRASIL, notably (i) risk management and analysis; (ii) prevention and detection of criminal activities; (iii) credit record checking; (iv) corporate restructuring; (v) activities related to information security and building security; (vi) management of relationship with customers, suppliers and communication between companies; (vii) internal and external audits; and (viii) establish and defend legal claims.

2.5. In the event of any order from public authorities requiring access to the information stored by BAT BRASIL, the relevant USER and subject data shall be notified so that they can adopt the defense measures they deem appropriate.

2.6. In any case, the data collected through the APPLICATIONS and arising from the SERVICES shall be stored only for the period required by the relevant regulations or until it is necessary for the purposes for which they were collected. The data will then be deleted, as provided for under the law, subject to the following cases: (i) compliance with any legal or regulatory obligation by BAT BRASIL; (ii) study by any research authority, whenever possible guaranteeing the personal data anonymization; (iii) transfer to third party, provided that the data processing requirements set out under the law are respected; or (iv) exclusive use BAT BRASIL, access by any third party being prohibited, and provided that the data are anonymized.

III. THIRD-PARTY SYSTEMS AND APPLICATIONS

3.1. BAT BRASIL shall not be responsible for the personal data processing carried out by third parties due to the use of systems, applications, websites and platforms in general that are their own. The processing performed by third parties shall be governed by their relevant Privacy Policies.
3.2.It will be up to the USERS, before using systems, applications, websites and platforms in general of any of BAT BRASIL’s partners, to read carefully the relevant PRIVACY POLICY, being aware that BAT BRASIL has no responsibility for or interference in the personal data processing that may be conducted by its partners or by any third parties.

IV. DATA VERACITY AND TIMELINESS

4.1.   The USERS guarantee that the data provided are true and current, undertaking to update them whenever there is any modification therein.

4.2. The USERS may access, correct or update their data at any time, as well as request the definitive deletion of their data from BAT BRASIL’s servers or  exercise any other rights provided for under Art. 18 of Law No. 13,709/18 through the Service Channel indicated in item VI hereof, being aware that in the event of deletion of their data they will no longer be able to access the features and services provided.

V. INFORMATION SECURITY

5.1. BAT BRASIL has in force appropriate technical and organizational security measures aimed at (i) protection against unauthorized access to stored data and backups; and (ii) preventing unauthorized changes, disclosures and/or destruction of any information held by BAT BRASIL.

5.2. We restrict access to information to people who need this information to provide the necessary support to the USERS, or to ensure the best operation of our digital services, products and/or tools. These individuals are bound by the duty of confidentiality and subject to disciplinary punishment, including termination of the employment contract and criminal prosecution in case of failure to comply with this obligation.

5.3. If the USERS suspect any misuse, loss or unauthorized access to their personal information, they shall immediately contact BAT BRASIL through the service channel provided for in item VI.

VI. SERVICE CHANNEL

6.1. To exercise any of your rights or if you have any questions or complaints regarding this PRIVACY POLICY please contact us through the phone +55 0800 7232221, the email privacidade_lgpd@bat.com or by mail sent to LEX – Legal and External Affairs department  of  BAT BRASIL, at Av. Republic of Chile, 330 – Centro, Zip Code: 20031-170, Rio de Janeiro/Brazil.

6.2. The USERS undertake to keep updated in their registration their e-mail address, through which the communications directed to them by BAT BRASIL will be made.

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